Notice for Revision U/s. 263: Limitation period to begin from date of assessment or date of re-assessment?

Indira Industries Vs. Pr. CIT (Madras High Court)

When a notice under Section 263 raises new issues, which are not subject matter of the re-assessment proceedings, then the two year period contemplated under Sub-section (2) of Section 263 would begin to run from the date of assessment and not from the date of re-assessment. In other words, the ratio laid down in Alagendran Finance case, particularly as elucidated in Paragraph 15 of the Alagendran Finance case, is to the effect that the two year limitation period stipulated

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